BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

WASHINGTON, DC 

______________________________________ 

) 

Motion and application of ) 

) Docket No. DOT-OST‐2010‐0018 

AMERICAN AIRLINES, INC. ) 

) 

in the matter of the 2010 U.S.-Haneda ) 

Combination Services Allocation Proceeding ) 

______________________________________ ) 

STATEMENT OF ALLIED PILOTS ASSOCIATION 

IN SUPPORT OF APPLICATION OF AMERICAN AIRLINES, INC. 

The Allied Pilots Association (“APA”), which represents the pilots of American Airlines, 

Inc. (“American”), strongly supports American’s application to acquire a slot pair from the 

Department of Transportation (“Department”) to provide service from Los Angeles 

International Airport (“LAX”) to Tokyo’s Haneda Airport (“Haneda”). As American explained 

in its Motion and Application dated October 2, 2014 (“Am. App.”), the reallocation of one U.S.-

Haneda daily frequency from Delta Air Lines (“Delta”) to American is manifestly in the public 

interest. 

As the Department well knows, the four daily slot pairs available to U.S. carriers for 

services between the U.S. and Haneda are a scarce, valuable resource. Delta’s current limited, 

seasonal service between Seattle and Haenda substantially underutilizes that resource. See Am. 

App. at 2; Consolidated Reply of American, Inc. (“Am. Reply”) at 6–9. 

In contrast, American has proposed a realistic plan for daily, year-round service between 

LAX and Haneda that is calibrated to improve the competitive structure of the U.S.-Tokyo 

market generally and respond to those characteristics that distinguish the U.S.-Haneda and U.S.-
Narita markets. See Am. App. at 5-6. Specifically, American proposes to provide daily nonstop 

LAX-Haneda service utilizing the 247-seat widebody Boeing 777 ("B-777") aircraft. !d. at 6. 

This service will maximize options for consumers traveling to, and doing business with, Japan. 

In addition, because current manning on the B-777 aircraft is approximately 23 pilots per 

aircraft, and the proposed service will require two such aircraft, American's proposal has the 

potential to create approximately 40-45 widebody pilot positions. See Declaration of Neil 

Roghair, ~ 3, Ex. A. As such, reallocating Delta's U.S.-Haneda slot pair to American would 

maximize the public benefit of the Haneda service for which the U.S. Government negotiated. 

AP A therefore urges the Department to grant American's application for allocation of a 

slot pair to provide service from LAX to Haneda. 

Dated: December 22, 2014 

Respectfully submitted, 

AN, P.C. 

1130 Connecticut Avenue, N.W. 

Suite 950 

Washington, D.C. 20036-3975 

(telephone) 202-496-0500 

(facsimile) 202-496-0555 

ejames@jamhoff.com 

Attorney for the Allied Pilots Association 
CERTIFICATE OF SERVICE 

I certify that on this 22nd day of December, 2014, a copy of the foregoing was served by 

electronic mail to the addressees identified below: 

paul.gretch@dot.gov

brian.hedberg@dot.gov 

brett.kruger@dot.gov

todd.homan@dot.gov 

peter.irvine@dot.gov

robert.finamore@dot.gov

EngleTS@state.gov

finstonma@state.gov

cristinasa@state.gov 

john.s.duncan@faa.gov

eugene.alford@ita.doc.gov

sascha.vanderbellen@delta.com 

chris.walker@delta.com

Mike.Donatelli@alpa.org

dino.atsalis@alpa.org

Doug.Ralph@alpa.org

jhill@cooley.com 

perkmann@cooley.com

bberlin@cooley.com 

Robert.Lamansky@hawaiianair.com

Hoyt.Zia@hawaiianair.com

Mark.Arimoto@hawaiianair.com

glindsey@lawa.org 

ishiwata.k@portseattle.org

safora.i@portseattle.org 

dan.weiss@united.com 

thomas.bolling@united.com

steve.morrissey@united.com 

gmurphy@crowell.com 

sseiden@crowell.com 

lhalloway@crowell.com

info@airlineinfo.com

howard.kass@aa.com 

robert.wirick@aa.com

abigail.donovan@aa.com 

francis.heil@aa.com

charles.hunnicutt@thompsonhine.com 

patricia.snyder@thompsonhine.com 

/s/ Edgar N. James 

Edgar N. James 
Exhibit A 
BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

WASHINGTON, DC 

______________________________________ 

) 

Motion and application of ) 

) Docket No. DOT-OST‐2010‐0018 

AMERICAN AIRLINES, INC. ) 

) 

in the matter of the 2010 U.S.-Haneda ) 

Combination Services Allocation Proceeding ) 

______________________________________ ) 

DECLARATION OF NEIL ROGHAIR 

I, NEIL ROGHAIR, declare as follows: 

1. I am the Vice President of the Allied Pilots Association (“APA”), the collective 

bargaining representative for the approximately 12,500 pilots employed by American Airlines, 

Inc. (“American” or the “Company”). I have been a pilot employed by American since February 

1, 1999. I also served 24 years in the Air Force, where I was a Major prior to my employment at 

American. In 2003, I was recalled to active duty as a Lt. Colonel in the Air Force during the Iraq 

war where I served as a commander in Baghdad. I returned to American in 2007. 

2. I joined the APA Negotiating Committee in October 2009 and served as Chair of 

that Committee from March 2010 through October 2013. Since July 1, 2013, I have served in 

the capacity of Vice President. 

3. The current manning on the B-777 aircraft at American is approximately 23 

pilots per aircraft. Putting two such aircraft into service from Los Angeles to Tokyo has the 

potential to create approximately 40-45 widebody pilot positions at American. 
I declare under penalty of perjury that the foregoing is true and correct based on my 

personal knowledge and on information from the business records of the AP A within my custody 

and control. 

tfec; o? ;{ c2(} / 1/' 

Date